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Prepare and
file entitlement forms with the Financial Industry Regulatory Authority to (A) establish an account on behalf of the
client with the Investment Adviser Registration Depositary and (B) obtain CRD numbers for any individuals affiliated
with the client as necessary.
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Travel to the client's offices and perform sufficient due diligence of the client and its employees and
interview the client employees to form the basis for disclosure to provide to the SEC.
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Prepare and file Part 1A and Part II of Form ADV (including all applicable schedules) to register the
client as an investment adviser with the SEC.
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Review any SEC comments to Form ADV, meet with SEC staff as necessary and research and prepare appropriate
responses to SEC comments.
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Develop compliance policies and procedures to be provided in a comprehensive compliance manual drafted
specifically for the client and reasonably designed to prevent violations of the Investment Advisers Act.
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Implement such compliance policies and procedures as provided in the compliance manual into the
client's business operations.
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Provide the services of a chief compliance officer, who will be designated the chief compliance officer
of the client in Part 1A of its Form ADV and will be responsible for administering the policies and procedures provided in the compliance manual
in accordance with the Investment Advisers Act.
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Prepare appropriate documents and submit filings to satisfy the compliance obligations of the client
under the Investment Advisers Act, Securities Act, Securities Exchange Act, Investment Company Act, Commodity Exchange Act, as well as U.S. blue
sky and state corporate law, including any future amendments to any such laws (collectively, the "Laws").
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Review and revise as necessary any marketing materials of the client to ensure proper compliance
with the Laws.
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Travel to the client's offices on a regular basis and as otherwise necessary to ensure proper
compliance with the Laws.
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Perform an annual compliance review to evaluate the adequacy of the client's policies and procedures
and the effectiveness of their implementation in accordance with the Investment Advisers Act.
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Work with SEC examiners before, during and after any surprise or scheduled audits and research and
respond to any SEC requests.
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Amend Part 1A and Part II of Form ADV and the client’s compliance manual as necessary in accordance with
(A) the Investment Advisers Act and (B) any changes to the Laws.
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